Telehealth Policy
Medicare telehealth policy has shifted dramatically for the entire healthcare industry in response to COVID-19, both policy unique to RHCs and more broadly within the fee-for-service community.
Table 1 breaks down the types of telehealth services RHC can bill for and how to bill for, including what was billable during the COVID-19 Public Health Emergency and the services’ temporary or permanent status. The majority of telehealth waivers will require further legislative action if they are to remain permanent.
All RHCs billing for telehealth should review the MLN Matters document: New and Expanded Flexibilities for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) During the COVID-19 Public Health Emergency (PHE).
In December 2020 CMS announced significant telehealth coinsurance changes.
Beginning January 2022 and not connected to the PHE, RHCs can bill and be reimbursed for mental health services provided via telehealth. More information can be found here.
NARHC continues to advocate for permanent coverage of all telehealth services and a revision of the RHC/FQHC payment policy to ensure that RHCs do not experience a disparity in reimbursement as compared to their fee-for-service counterparts who receive payment parity.Table 2 highlights the various Medicare telehealth waivers and their current status as of May 2023.
With any questions, please email Sarah Hohman at Sarah.Hohman@narhc.org.
Table 1
Name of Telehealth Service |
Brief Description |
How to Bill |
Reimbursement Rate |
Relevant Dates |
Virtual Check-In or Virtual Care Communications |
Remote evaluation - G2010 Brief communication with patient (5 min) - G2012
|
G0071 052X |
2022: 2023: |
Permanent |
Digital e-Visits |
Online evaluation and management 99421-99423 |
G0071 |
2022: 2023: |
Only billable |
One to one substitutes for in-person services/visits List of allowable services maintained by CMS |
G2025 Rev Code 052X Costs and encounters carved out of cost report |
2022: 2023: |
Currently |
|
Mental Health Telehealth Visits |
One to one substitutes for in-person mental health services/visits CPT codes that can be billed with 0900 revenue code |
Rev Code 0900 Use proper mental health CPT code Modifier CG always Modifier 95 if audio-video Modifier FQ or 93 if audio-only |
All-Inclusive |
Permanent *Occasional in-person |
Chronic Care Management/ Principal Care Management |
99484, 99487, 99490, 99491, 99424, and 99425 = G0511 99492, 99493 = G0512 |
G0511- Care Management G0512- Psychiatric Care Management |
G0511 2022- G0511 2023- G0512 2022- G0512 2023- |
|
Transitional Care Management | Supporting the additional work provided to patients following discharge from an acute care setting to prevent errors and readmissions. | 99495, 99496 on an RHC claim, either alone or with other payable services | If it is the only medical service provided on that day with an RHC or FQHC practitioner it is paid as a stand-alone billable visit. If it is furnished on the same day as another visit, only one visit is paid. | Covered since January 1, 2013 |
Table 2
Medicare Policy Area | Current Policy and Duration of Flexibility/Waiver |
Originating Site/Geographic Requirements | Patients can receive telehealth services in their home or anywhere else through December 31, 2024. |
Distant Site Requirements | RHC providers can serve as telehealth distant site providers through December 31, 2024. RHC providers can offer telehealth services from any location, including their home, during this period. |
Billing/Cost Reporting Requirements | Please see table above. G2025 policy for medical telehealth visits remains in effect through December 31, 2024. |
Modality | The Office of Civil Rights allowed for “non-public facing” remote communication products to be used for telehealth services, “exercising discretion” on stringent HIPAA compliant platform requirements. This ended on May 11, 2023 |